Jonah Redfern The European Commission has classified OpenAI's ChatGPT as a "very large online search engine" under the EU's Digital Services Act — the first time Brussels has applied the category to an AI chatbot — and designated Reddit and Roblox "very large online platforms", according to Euronews. All three have four months to comply with the DSA's strictest tier of obligations.
That tier applies to services with over 45 million average monthly EU users — about a tenth of the bloc's population — under Article 33 of Regulation (EU) 2022/2065. Designated companies must run annual "systemic risk" assessments covering illegal content, harm to minors and threats to civic discourse (Article 34), adopt mitigation measures (Article 35), submit to independent audits (Article 37) and maintain a public repository of every EU ad, including funder and targeting data (Article 39).
- As a designated search engine, ChatGPT must offer users an option to view non-personalised results and disclose the main parameters behind its ranking or recommender logic — obligations previously applied to services like Google Search and Bing.
- Reddit must publish its first EU systemic-risk report covering moderation across its forums, subject to independent audit.
- Roblox, whose user base skews young, faces the DSA's separate minor-protection duties under Article 28, in addition to the standard VLOP requirements.
The compliance period runs from notification of the decision, per Politico. OpenAI, Reddit and Roblox can contest the designation before the EU's General Court, a route Meta, TikTok and X have already used against earlier VLOP rulings, per Bloomberg. Unresolved: how the Commission will apply search-engine transparency duties, designed for a page of ranked links, to a chatbot that answers in conversation and has no results page at all.
